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Unlawful Internet Gambling Enforcement Act (UIGEA) and Regulation GG Policy
It is KeyPoint Federal Credit Union's policy to comply with Regulation GG, as mandated by the Unlawful Internet Gambling Enforcement Act (UIGEA) and enforced by the Federal Trade Commission. This regulation requires credit unions to put in place policies and procedures designed to prevent illegal internet gambling operations from setting up accounts and to prevent card transactions from being made to unlawful internet gambling operations.
New Business Accounts: At account opening, business members will be notified that KeyPoint Federal Credit Union prohibits use of accounts to participate, in any form, in unlawful Internet gambling. When a commercial member comes in to open an account, the member must certify in writing that the business will not engage in an unlawful Internet gambling business. If the potential business member engages in an internet gambling business, the member must provide (1) documentation to show that the internet gambling business is lawful and (2) a written commitment by the member to notify the credit union of any changes in its legal authority to engage in such business.
Privacy Policy
OBJECTIVE
The Credit Union is committed to meeting all financial needs of its members without compromising the valued relationship we have with our members. This is the Directors, management and staff of the Credit Union is our highest priority. In their daily transactions and dealing with us, our members furnish us sensitive and confidential information. We are committed to protecting our member's privacy provisions. To ensure that our members continue their trust in our Credit Union, we adopt the following policy.
RESPONSIBILITY
The Credit Union shall comply with all NCUA Privacy Rules and all applicable state privacy laws affecting us. The Credit Union’s Compliance Officer Darlene B. Lockhart shall be responsible for ensuring that all Directors, management and staff are properly trained in the various privacy laws affecting the Credit Union. The Compliance Officer shall continuously monitor privacy regulations. The Chairman of the Credit Union shall ensure that the Credit Union has fully complied with all privacy laws.
PRIVACY PRACTICES
A. No Credit Union employee shall request information from a member unless that information is necessary to conduct or complete a transaction, process an application, or is for business purposes.
B. The Credit Union shall only disclose the information it collects from its members and former members to affiliates of the Credit Union, transaction processors, other financial institutions, other service providers of the Credit Union , and those parties allowed by law, in accordance with 12 CFR Parts 716.13, 716.14, and 716.15.
C. The Credit Union shall enter into joint agreements with other financial institutions and service providers to ensure that those parties follow our strict confidentiality procedures and do not use our member’s personal information for any purpose other than the purpose of our agreement with them.
D. The Credit Union shall restrict access to our member’s information to those employees who need to know that information to provide products and services. The Credit Union shall maintain physical, electronic and procedural safeguards that comply with federal and state regulations in order to protect our member’s personal information.
E. The Credit Union shall create and disclose a privacy notice to all Credit Union members upon establishing a membership with the Credit Union and at least annually thereafter.
JOINT MARKETING AGREEMENT
Prior to sharing non-public, personal information about our members with third parties, the Credit Union must disclose information it will share, and provide the members the opportunity to stop the disclosure (“opt out”).
The “opt out” requirement will not apply if the Credit Union enters into a “Joint Marketing Agreement” with the third party. A written contract between the Credit Union and the third party provider must in the following:
• A provision requiring confidentiality of the information disclosed. In other words, a requirement that the companies will not share the information with other third parties.
• A provision forbidding the use of the information for any purpose other than the purpose of the contract. In order works, a requirement that the companies will only use the information shared for the sole purposes of the contract and will not use the information to market other services/products it may provide.
For existing contracts with third party providers that were entered into prior to July 1, 2000, the Credit Union has until July 1, 2002 to ensure that the joint marketing agreement language is incorporated into the contract.
For new contracts with third party providers entered into after July 1, 2000, the joint marketing agreement language must contained in the contract at the time of entering into the contract in order to take advantage of this exception.
Truth-in-Savings
Except as specifically described, the following disclosures apply to all of the accounts. All accounts described in this Truth-In-Savings Disclosure are share accounts.
1. Rate Information. The Annual Percentage Yield is a percentage rate that reflects the total amount of dividends to be paid on an account based on the dividend rate and frequency of compounding for an annual period. For all accounts, the Dividend Rate and Annual Percentage Yield are fixed and will be in effect for the initial term of the account. For accounts subject to dividend compounding, the Annual Percentage Yield is based on an assumption that dividends will remain on deposit until maturity. A withdrawal of dividends will reduce earnings.
2. Dividend Period. For each account the dividend period is the account’s term. The dividend period begins on the first day of the term and ends on the maturity date.
3. Dividend Compounding and Crediting. The compounding and crediting frequency of dividends are stated in the Rate Schedule.
4. Balance Information. The minimum balance requirements applicable to each account are set forth in the Rate Schedule. To open any account you must deposit or already have on deposit at least the par value of one full share in a Share Savings account. The par value amount is stated in the Fee Schedule. Some accounts may have additional minimum opening deposit requirements. For all accounts, dividends are calculated by the Average Daily Balance method, which applies a periodic rate to the balance in the account each day.
5. Accrual of Dividends. For all accounts, dividends will begin to accrue on noncash deposits (e.g. checks) on the business day you make the deposit to your account. If you close your account before accrued dividends are credited, accrued dividends will not be paid.
6. Transaction Limitations. For all accounts, after your account is opened you may make withdrawals subject to the early withdrawal penalties stated below.
7. Maturity. Your account will mature as stated on this Truth-in-Savings Disclosure or on your Account Receipt or Renewal Notice.
Early Withdrawal Penalty. We may impose a penalty if you withdraw from your account before the maturity date.
How the Penalty Works. The penalty is calculated as a forfeiture of part of the dividends that have been or would be earned on the account. It applies whether or not the dividends have been earned. In other words, if the account has not yet earned enough dividends or if the dividend has already been paid, the penalty will be deducted from the principal.
Exceptions to Early Withdrawal Penalties. At our option, we may pay the account before maturity without imposing an early withdrawal penalty under the following circumstances:
When an account owner dies or is determined legally incompetent by a court or other body of competent jurisdiction
Where the account is an Individual Retirement Account (IRA) and any portion is paid within seven (7) days after the establishment; or where the account is a Keogh Plan (Keogh) provided that the depositor forfeits an amount of at least equal to the simple dividends earned in the amount withdrawn; or where the account is an IRA or Keogh and the owner attains age 59 ½ or becomes disabled.
Renewal Policy. The renewal policy for your accounts is stated in the Rate Schedule. For all accounts, your account will automatically renew for another term upon maturity. You have a grace period of ten (10) days after maturity in which to withdraw funds in the account without being charged an early withdrawal penalty.
Nontransferable/Nonnegotiable. Your account is nontransferable and nonnegotiable.
FEE SCHEDULE
Share Value
- Par value of one share $10.00
The rates appearing in this Schedule are accurate as of the Effective Date indicated on this Truth-in-Savings Disclosure. If you have any questions or require current rate and fee information on your accounts, please call the Credit Union.
Funds Availability
General Policy — Our policy is to make funds from your cash and check deposits available to you on the same business day that we receive your deposit. Electronic direct deposits will be available on the day we receive the deposit. Once they are available, you can withdraw the funds in cash and we will use the funds to pay checks that you have written. For determining the availability of your deposits, every day is a business day, except Saturday, Sunday, and federal holidays. If you make a deposit after we have closed or on a day that we are not open, we will consider that the deposit was made on the first business day we are open.
Reservation of Right to Hold — In some cases, we will not make all of the funds that you deposit by check available to you on the same business day that we receive your deposit. Depending on the type of check that you deposit, funds may not be available until the fifth (5th) business day after the day of your deposit. However, the first $200.00 of your deposit will be available on the first (1st) business day after the day of your deposit. If we are not going to make all of the funds from your deposit available on the same business day, we will notify you at the time you make your deposit. We will also tell you when the funds will be available. If your deposit is not made directly to one of our employees, or if we decide to take this action after you have left the premises, we will mail you the notice by the next business day after we receive your deposit. If you will need the funds from a deposit right away, you should ask us when the funds will be available.
Holds on Other Funds— If we cash a check for you that is drawn on another financial institution, we may withhold the availability of a corresponding amount of funds that are already in your account. Those funds will be available at the time funds from the check we cashed would have been available if you had deposited it. If we accept for deposit a check that is drawn on another institution, we may make funds from the deposit available for withdrawal immediately, but delay your availability to withdraw a corresponding amount of funds that you have on deposit in another account with us. The funds in the other account would then not be available for withdrawal until the time periods for the type of check that you deposited.
Longer Delays May Apply— We may delay your ability to withdraw funds deposited by check into your account an additional number of days for these reasons:
• We believe a check will not be paid.
• You deposit checks totaling more than $5000 on any one day.
• You deposit a check that has been returned unpaid.
• You have overdrawn your account repeatedly in the last six (6) months.
• There is an emergency, such as equipment failure.
We will notify you if we delay your ability to withdraw funds for any of these reasons, and we will tell you when the funds will be available. They will generally be available no later than the seventh (7th) business day after the day of your deposit.
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